Wood v. Carl's Jr. et al, No. 2:2020cv02329 - Document 53 (D. Nev. 2021)

Court Description: ORDER Denying 52 Motion to Extend Discovery Deadlines without prejudice. Signed by Magistrate Judge Brenda Weksler on 8/31/2021. (Copies have been distributed pursuant to the NEF - DRS)

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Wood v. Carl's Jr. et al Doc. 53 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 1 of 15 1 JOSH COLE AICKLEN Nevada Bar No. 7254 2 JESSELYN V. DE LUNA Nevada Bar No. 15031 3 LEWIS BRISBOIS BISGAARD & SMITH LLP 6385 S. Rainbow Boulevard, Suite 600 4 Las Vegas, Nevada 89118 TEL: 702.893.3383 5 FAX: 702.893.3789 josh.aicklen@lewisbrisbois.com 6 jesselyn.deluna@lewisbrisbois.com Attorneys for Defendant 7 BTO INVESTMENTS, INC. 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 12 HOLLY MARIE WOOD, an individual, 2-20-cv-02329-APG-BNW Plaintiff, 13 14 CASE NO. vs. 15 CARL’S JR., operated and owned by BTO INVESTMENTS, a Delaware corporation; 16 S.L. INVESTMENTS, a Nevada corporation; CKE RESTAURANTS, INC., a 17 Delaware corporation; CARL’S JR. RESTAURANTS, LLC, a foreign limited 18 liability company; CARL KARCHER ENTERPRISES, INC., a foreign 19 corporation; CKE RESTAURANTS HOLDINGS, INC., a foreign corporation; 20 RUCEY MOLINA CRUZ, an individual; DOES 1 through 10, inclusive; ROE 21 CORPORATIONS/ENTITIES 1 through 10, inclusive; 22 Defendants. 23 DEFENDANTS’ JOINT MOTION TO EXTEND DISCOVERY DEADLINES 24 25 COME NOW, Defendants, BTO INVESTMENTS, INC., S.L. INVESTMENTS, CKE 26 RESTAURANTS, INC., CARL’S JR. RESTAURANTS, LLC, CARL KARCHER 27 ENTERPRISES, INC., and CKE RESTAURANTS HOLDINGS, INC. (hereinafter LEWIS 28 BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 Dockets.Justia.com Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 2 of 15 1 collectively, “Defendants”), by and through their respective counsel of record, and 2 pursuant to FRCP 26 and LR 26-3, move this Court for an Order extending discovery 3 deadlines for good cause shown. 4 This Motion is made and based upon LR IA 6-1, LR 7-1, and LR 26-3, the 5 memorandum of points and authorities, the declaration of Jesselyn V. De Luna, and any 6 oral argument the Court deems appropriate. Respectfully submitted, 7 8 DATED this 30th day of August, 2021. 9 10 LEWIS BRISBOIS BISGAARD & SMITH LLP 11 12 ALVERSON TAYLOR & SANDERS /s/ Josh Cole Aicklen /s/ Karie N. Wilson Josh Cole Aicklen, Esq. 13 Nevada Bar No. 7254 Jesselyn V. De Luna, Esq. 14 Nevada Bar No. 15031 6385 South Rainbow Boulevard, Suite 600 15 Las Vegas, Nevada 89118 Attorneys for Defendant 16 BTO INVESTMENTS, INC. J. Bruce Alverson, Esq. Nevada Bar No. 1339 Karie N. Wilson, Esq. Nevada Bar No. 7957 6605 Grand Montecito Parkway, Suite 200 Las Vegas, Nevada 89149 Attorneys for Defendants CARL’S JR. RESTAURANTS LLC, CKE RESTAURANTS HOLDINGS, INC., CKE RESTAURANTS, INC., AND CARL KARCHER ENTERPRISES, INC 17 18 19 20 21 GORDON REES SCULLY MANSUKHANI LLP /s/ Rachel L. Wise 22 Robert S. Larsen, Esq. 23 Nevada Bar No. 7785 Rachel L. Wise, Esq. 24 Nevada Bar No. 12303 300 South Fourth Street, Suite 1550 25 Las Vegas, Nevada 89101 26 Attorneys for Defendant S.L. INVESTMENTS 27 LEWIS 28 BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 2 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 3 of 15 DECLARATION OF JESSELYN V. DE LUNA, ESQ. 1 2 I, JESSELYN V. DE LUNA, declare and state as follows: 3 1. I am an associate in the law firm of Lewis Brisbois Bisgaard & Smith, LLP, 4 am duly licensed to practice law in the State of Nevada, and am an attorney for 5 Defendant BTO Investments, Inc. in the above-captioned matter. 6 2. I have personal knowledge of the facts set forth hereunder and am 7 competent to testify to the same. 8 3. In late July, our office proposed a mediation in this case, to which all parties 9 agreed. A true and correct copy of this email chain is attached hereto as Exhibit A. 10 4. The mediation was eventually scheduled for Monday, September 27, 2021 11 with Judge Trevor Atkin (Ret.) at Advanced Resolution Management. 12 5. In light of the pending mediation, it was discussed that major discovery 13 would be paused to allow the parties time to prepare for the mediation without incurring 14 potentially unnecessary discovery costs. To this end, it was agreed by all parties that the 15 scheduled deposition of Plaintiff Wood, which was set to take place on Monday, July 26, 16 2021, was cancelled. See, Exhibit A. 17 6. Initial expert disclosures are currently due on September 20, 2021, exactly 18 one week before the scheduled mediation. Given the parties’ interest in avoiding 19 unnecessary discovery expenses, a draft Amended Discovery Plan and Scheduling Order 20 was circulated on August 20, 2021. All parties agreed to the extension except for 21 Plaintiff. I called Plaintiff’s counsel’s office and spoke with Paul Padda, Esq. who advised 22 that an answer would be provided the following Monday. On Monday, August 23 rd, 23 Plaintiff’s counsel declined to stipulate to an extension of deadlines. A true and correct 24 copy of this email chain is attached hereto as Exhibit B. 25 7. Because of Plaintiff’s refusal to extend the current deadlines, the mediation 26 was cancelled to allow the parties time to focus on completing discovery as soon as 27 possible in order to go to trial. However, due to certain circumstances discussed herein, LEWIS 28 defense counsel for BTO Investments, Inc., S.L. Investments, and the CKE Defendants BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 3 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 4 of 15 1 agree that an extension of time is necessary. As such, Defendants are forced to bring 2 forth the instant Joint Motion. 8. 3 The instant Motion is timely as it is brought no later than 21 days before the 4 expiration of the next deadline, September 20, 2021, in accordance with LR 26-3. 9. 5 The instant Motion is brought in good faith and not for the purpose of undue 6 delay. 7 I declare under penalty of perjury under the laws of the United States of America 8 that the foregoing is true and correct. 9 Executed on August 30, 2021 in Las Vegas, Nevada. 10 11 /s/ Jesselyn V. De Luna 12 ________________________ JESSELYN V. DE LUNA 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 LEWIS 28 BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 4 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 5 of 15 MEMORANDUM OF POINTS AND AUTHORITIES 1 2 I. INTRODUCTION 3 This is a civil rights employment discrimination, sexual assault, and battery action 4 brought by Plaintiff Holly Marie Wood (“Plaintiff”) against CKE Restaurants, Inc., Carl’s Jr. 5 Restaurants, LLC, Carl Karcher Enterprises, Inc., and CKE Restaurants Holdings, Inc. 6 (hereinafter collectively, “CKE Defendants”), BTO Investments, Inc., 7 Investments. and S.L. Plaintiff alleges Defendants are vicariously liable for her injuries. See 8 generally, Complaint. Plaintiff filed her Complaint on September 18, 2020. 9 Local Rule 26-1(b)(1) provides that “unless otherwise ordered, discovery periods 10 longer than one hundred and eighty (180) days from the date the first defendant answers 11 or appears will require special scheduling review.” On February 23, 2021, the Court 12 granted the parties’ Proposed Discovery Plan and Scheduling Order, approving the 13 parties’ request for a 240-day discovery period, as reasonable and necessary, in light of 14 the impact of the COVID-19 pandemic. (Doc. 30). On June 25, 2021, the Court granted 15 the parties’ Amended Plan and Scheduling Order, approving the parties’ request that an 16 additional 90 days be added to the discovery period, for a total of 330 days, based on 17 certain extenuating circumstances, including the unsuccessful Early Neutral Evaluation 18 on March 10, 2021 leading to the entry of Defendant S.L. Investments into the suit, the 19 withdrawal of CKE Defendants’ former attorneys and the appearance of their current 20 attorneys, the pending service of Defendant Rucey Molina Cruz, written discovery 21 extensions, the continuation of Plaintiff’s deposition, the anticipated need for the 22 depositions of additional fact witnesses and Plaintiff’s treating physicians, and inadvertent 23 errors in the calculation of the original Order. (Doc. 48). 24 Defendants now propose that an additional 60 days be added to the 330-day 25 discovery period, for a total of 390 days. In late July, counsel for BTO Investments, Inc. 26 proposed a mediation in this case, to which all parties agreed. A true and correct copy of 27 this email chain is attached hereto as Exhibit A. The mediation was eventually scheduled LEWIS 28 for Monday, September 27, 2021 with Judge Trevor Atkin (Ret.) at Advanced Resolution BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 5 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 6 of 15 1 Management. In light of the pending mediation, it was discussed that major discovery 2 would be paused to allow the parties time to prepare for the mediation without incurring 3 potentially unnecessary discovery costs. Consequently, the scheduled deposition of 4 Plaintiff, which was set to take place on Monday, July 26, 2021, was cancelled. See, 5 Exhibit A. Initial expert disclosures are currently due on September 20, 2021, which was 6 7 exactly one week before the scheduled mediation. Given the parties’ interest in avoiding 8 unnecessary discovery expenses, a draft Amended Discovery Plan and Scheduling Order 9 was circulated on August 20, 2021. All parties agreed to the extension except for 10 Plaintiff. Counsel for BTO Investments, Inc. called Plaintiff’s counsel’s office and spoke 11 with Paul Padda, Esq. who advised that an answer would be provided the following 12 Monday. See, Declaration of Jesselyn V. De Luna. On Monday, August 23rd, Plaintiff’s 13 counsel declined to stipulate to an extension of deadlines. A true and correct copy of this 14 email chain is attached hereto as Exhibit B. Because of Plaintiff’s refusal to extend the 15 current deadlines, the mediation was cancelled to allow the parties time to focus on 16 completing discovery to go to trial as soon as possible. However, given the expectation 17 that the parties would participate in mediation, Plaintiff’s deposition was not re-noticed. In 18 addition to re-noticing Plaintiff’s deposition, the parties will also have to produce their 19 initial expert disclosures in an insufficient time frame. Furthermore, due to certain 20 circumstances detailed below, defense counsel for BTO Investments, Inc., S.L. 21 Investments, and the CKE Defendants agree that an extension of time is necessary. As 22 such, Defendants bring forth the instant Joint Motion. 23 II. COMPLIANCE WITH LR 26-3 TO SHOW GOOD CAUSE FOR EXTENSION 24 Pursuant to the requirements of LR 26-3 regarding extending scheduled deadlines, 25 Defendants have included herewith: LEWIS 26 A. A statement specifying the discovery completed; 27 B. A specific description of the discovery that remains to be completed; 28 C. The reasons why the deadline was not satisfied or the remaining discovery BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 6 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 7 of 15 1 was not completed within the time limits set by the discovery plan; and 2 D. A proposed schedule for completing all remaining discovery. 3 A. Statement Specifying the Discovery Completed 4 The parties have conducted the following discovery to date: 5 1. Plaintiff served her Initial Disclosures on March 3, 2021 6 2. Defendant BTO Investments, Inc. served its Initial Disclosures on March 5, 8 3. CKE Defendants served their Initial Disclosures on March 3, 2021; 9 4. Defendant BTO Investments, Inc. propounded its First Set of Interrogatories 7 2021 10 and First Set of Requests for Production to Plaintiff on March 25, 2021; 11 5. Plaintiff served her First Supplement to Initial Disclosures on April 26, 2021; 12 6. Plaintiff served her Responses to Defendant BTO Investments, Inc.’s First 13 Set of Interrogatories and First Set of Requests for Production on April 26, 2021; 14 7. Plaintiff propounded her First Set of Interrogatories and First Set of 15 Requests for Production to Defendant BTO Investments, Inc. on April 27, 2021; 16 8. CKE Defendants served their First Supplement to Initial Disclosures on April 17 30, 2021; 18 9. CKE Defendants propounded their First Set of Interrogatories and First Set 19 of Requests for Production to Plaintiff on June 10, 2021; 20 10. Defendant S.L. Investments served Initial Disclosures on June 19, 2021; 21 11. Defendant BTO Investments, Inc. served its First Supplement to Initial 22 Disclosures on June 25, 2021; 23 12. Defendant BTO Investments, Inc. served its Responses to Plaintiff’s First 24 Set of Interrogatories and First Set of Requests for Production; 25 13. Plaintiff served her Responses to the CKE Defendants’ First Set of 26 Interrogatories and First Set of Requests for Production on July 12, 2021; 27 LEWIS 14. Plaintiff propounded her Second Set of Interrogatories to Defendant BTO 28 Investments, Inc. on July 28, 2021; BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 7 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 8 of 15 1 15. Plaintiff propounded her First Set of Requests for Production to Defendant 2 S.L. Investments on July 28, 2021; and 3 16. Defendant S.L. Investments propounded its First Set of Requests for 4 Admissions to Defendant BTO Investments, Inc. on August 6, 2021. 5 B. Specific Description of the Discovery that Remains to Be Completed 6 1. Additional Written Discovery; 7 2. Initial Expert Disclosures; 8 3. Rebuttal Expert Disclosures; 9 4. Deposition of Plaintiff; 10 5. Independent Medical Examination of Plaintiff; 11 6. Vocational Interview of Plaintiff; 12 7. Depositions of Respective FRCP 30(b)(6) Witnesses; 13 8. Depositions of Percipient Witnesses; 14 9. Depositions of Treating Physicians; 15 10. Depositions of Plaintiff’s Expert Witnesses; 16 11. Depositions of Defendants’ Expert Witnesses; and 17 12. Any Additional Discovery Deemed Necessary. 18 C. Reasons Why the Deadline Was Not Satisfied or the Remaining Discovery Was Not Completed Within the Time Limits Set by the Discovery Plan 19 LEWIS 20 Defendants respectfully request that an additional 60 days be added to the 330- 21 day discovery period, for a total of 390 days. The parties have been diligently working to 22 complete discovery in accordance with the current deadlines. However, certain factors 23 have necessitated an extension of the current deadlines. 24 First, the parties agreed to mediate the case, setting the mediation for September 25 27, 2021. This was done with the understanding that major discovery would be paused to 26 allow the parties time to prepare for the mediation without incurring potentially 27 unnecessary discovery costs. 28 cancelled. Plaintiff now refuses to stipulate to extend discovery deadlines, which would Consequently, Plaintiff’s scheduled deposition was BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 8 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 9 of 15 1 force the parties to depose Plaintiff and gather experts within an insufficient time frame. 2 Second, Defendant BTO Investment Inc. has a new handling attorney. Defendant 3 BTO Investments, Inc. is represented by the law firm Lewis Brisbois Bisgaard & Smith, 4 LLP. The original handling attorney, Bruce C. Young, Esq., left the firm. The case was 5 internally reassigned to Josh Cole Aicklen, Esq. as the primary handling attorney. 6 Third, Plaintiff herself has a pending extension. She has not yet been able to 7 effectuate service of the Summons and Complaint on Defendant Rucey Molina Cruz. 8 Plaintiff therefore sought and was granted additional time to effectuate service. The 9 Court’s Order dated May 5, 2021, extended service upon Defendant Rucey Molina Cruz 10 “up to and including 180 days from [the] Order,” or until November 1, 2021. (Doc. 44). As 11 of the date of this filing, Plaintiff has not advised as to the status of service and no 12 confirmation has been provided to indicate that Mr. Cruz has been served. 13 Fourth, the parties also anticipate the need for the depositions of additional fact 14 witnesses, including former employees of the restaurant where Plaintiff was previously 15 employed. Some of these witnesses may be difficult to locate as several were also 16 teenagers or young adults who stopped working for Defendant BTO in 2018, nearly three 17 years ago. In addition, Plaintiff is seeking emotional distress damages and damages for 18 alleged future medical care and the parties therefor anticipate the need for depositions of 19 Plaintiff’s treating physicians including, but not limited to, physicians at UMC Trauma, Dr. 20 Norton Roitman, Dr. Ruth Ramirez, and Dr. Ron Zedek. Coordinating these depositions 21 and accommodating the work and vacation schedules for the witnesses and the attorneys 22 involved is expected to necessitate additional discovery time. 23 For all these reasons, the parties respectfully request that the applicable discovery 24 deadlines be extended an additional 60 days. Upon a showing of good cause, this Court 25 is authorized to modify the discovery schedule. See, FRCP 6(b)(1)(A); LR 26-4. “The 26 district court may modify the pretrial schedule if it cannot reasonably be met despite the 27 diligence of the party seeking the extension.” Johnson v. Mammoth Recreations, Inc., LEWIS 28 975 F.2d 604, 609 (9th Cir. 1992). Based upon the date the first Defendant answered or BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 9 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 10 of 15 1 otherwise appeared (December 23, 2020) (Doc. 1), the undersigned parties hereby 2 propose the following discovery schedule pursuant to the LR 26-1 (April 17, 2020): 3 D. Proposed Schedule for Completing All Remaining Discovery 4 Defendants submit the following proposed discovery plan, which represents a sixty 5 (60) day extension of the remaining discovery deadlines: 6 7 Current Discovery Plan & Scheduling Order Event Proposed Amended Discovery Plan & Scheduling Order Current Deadline Proposed Deadline November 18, 2021 (Thursday) January 17, 2022 (Monday) 8 9 Discovery Cut-Off 10 [390 Days from date first defendant answers or appears – LR 26-1 (b)(1)] 11 12 13 14 15 Amending Pleadings Adding Parties August 20, 2021 (Friday) October 19, 2021 (Tuesday) [90 Days Before Close of Discovery – LR 26-1(b)(2)] 16 17 18 Initial Expert Disclosures September 20, 2021 (Monday) November 18, 2021 (Thursday) [60 Days Before Close of Discovery – LR 26-1(b)(3)] 19 20 21 22 Rebuttal Expert Disclosures October 20, 2021 (Wednesday) December 20, 2021 (Monday) [30 days after the Initial Disclosure of Experts - LR 26-1(b)(3) is a Saturday, 12/18/21] 23 24 25 26 Dispositive Motions December 20, 2021 (Monday) February 16, 2022 (Wednesday) 27 LEWIS [30 Days After Close of Discovery – LR 26-1(b)(4)] 28 BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 10 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 11 of 15 1 Pre-Trial Order 2 January 19, 2022 March 18, 2022 [30 Days After the Dispositive Motion Deadline - LR 26-1(b)(5)] 3 4 5 With respect to the Pre-Trial Order, if dispositive motions are filed, the deadline for 6 filing a Joint Pre-Trial Order will be suspended until 30-days after a decision on the 7 dispositive motion(s) is/are rendered or until further Court notice. See, Local Rule 26-1 8 (b)(5). 9 /// 10 /// 11 /// 12 /// 13 /// 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// LEWIS 28 BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 11 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 12 of 15 1 III. CONCLUSION 2 Based on the foregoing, Defendants, BTO Investments, Inc., S.L. Investments, 3 CKE Restaurants, Inc., Carl’s Jr. Restaurants, LLC, Carl Karcher Enterprises, Inc., and 4 CKE Restaurants Holdings, Inc., respectfully request that this Court extend the discovery 5 period by sixty (60) days from the current deadline and enter a new Scheduling Order 6 with the dates proposed above. Respectfully submitted, 7 8 DATED this 30th day of August, 2021. 9 10 LEWIS BRISBOIS BISGAARD & SMITH LLP 11 12 /s/ Josh Cole Aicklen Josh Cole Aicklen, Esq. 13 Nevada Bar No. 7254 Jesselyn V. De Luna, Esq. 14 Nevada Bar No. 15031 6385 South Rainbow Boulevard, Suite 600 15 Las Vegas, Nevada 89118 Attorneys for Defendant 16 BTO INVESTMENTS, INC. 17 18 ALVERSON TAYLOR & SANDERS /s/ Karie N. Wilson J. Bruce Alverson, Esq. Nevada Bar No. 1339 Karie N. Wilson, Esq. Nevada Bar No. 7957 6605 Grand Montecito Parkway, Suite 200 Las Vegas, Nevada 89149 Attorneys for Defendants CARL’S JR. RESTAURANTS LLC, CKE RESTAURANTS HOLDINGS, INC., CKE RESTAURANTS, INC., AND CARL KARCHER ENTERPRISES, INC 19 20 GORDON REES SCULLY MANSUKHANI LLP 21 Order 22 /s/ Rachel L. Wise Robert S. Larsen, Esq. 23 Nevada Bar No. 7785 Rachel L. Wise, Esq. 24 Nevada Bar No. 12303 300 South Fourth Street, Suite 1550 25 Las Vegas, Nevada 89101 26 Attorneys for Defendant IT IS ORDERED that ECF No. 52 is DENIED without prejudice. It does not appear that the parties met and conferred in accordance with LR IA 1-3(f). IT IS SO ORDERED DATED: 1:09 pm, August 31, 2021 S.L. INVESTMENTS 27 LEWIS BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE 28 BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 12 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 13 of 15 CERTIFICATE OF SERVICE 1 2 Pursuant to FRCP 5(b), I certify that I am an employee of LEWIS BRISBOIS 3 BISGAARD & SMITH LLP, and that on this 30th day of August, 2021, I did cause a true 4 5 and correct copy of the foregoing DEFENDANTS’ JOINT MOTION TO EXTEND DISCOVERY DEADLINES to be filed with the Court and served to the following: 6 7 Paul S. Padda, Esq. Tony L. Abbatangelo, Esq. 8 PAUL PADDA LAW, PLLC 4030 S. Jones Boulevard, Unit 30370 9 Las Vegas, Nevada 89173 10 Tel: (702) 366-1888 Fax: (702) 366-1940 11 Email: psp@paulpaddalaw.com tony@paulpaddalaw.com 12 Attorneys for Plaintiff Rachel I. Wise Robert S. Larsen, Esq. GORDON REES SCULLY MANSUKHANI, LLP 300 S. Fourth Street, Suite 1550 Las Vegas, NV 89101 Tel: (702) 577-9300 Fax: (702) 255-2858 Email: rlarsen@grsm.com Email: rwise@grsm.com Attorneys for Defendant S.L. Investments 13 14 J. Bruce Alverson, Esq. Karie N. Wilson, Esq. 15 ALVERSON TAYLOR & SANDERS 6605 Grand Montecito Pkwy, Ste. 200 16 Las Vegas, NV 89149 Tel: (702) 384-7000 17 Fax: (702) 385-7000 18 Email: kwilson@alversontaylor.com Attorneys for Defendants Carl’s Jr. 19 Restaurants LLC, CKE Restaurants Holdings, Inc., CKE Restaurants, Inc., 20 and Carl Karcher Enterprises, Inc. 21 22 By /s/ Lori Tollerud An Employee of LEWIS BRISBOIS BISGAARD & SMITH LLP 23 24 25 26 27 LEWIS 28 BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4815-8331-3656.1 13 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 14 of 15 Case 2:20-cv-02329-APG-BNW Document 53 52 Filed 08/31/21 08/30/21 Page 15 of 15

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